OSHA ETS COVID-19 Vaccination Policy

Now that COVID-19 vaccines have been fully approved by the U.S. Food and Drug Administration (FDA), and in accordance with the Occupational Safety and Health Administration’s (OSHA’s) emergency temporary standard for private employers with 100 or more workers, LaGrange College is adopting this policy to comply with OSHA’s requirements, align with public health recommendations from the Centers for Disease Control and Prevention (CDC) and local health authorities, and comply with all applicable federal, state and local laws. Compliance with this policy is a condition of your continued employment. Please read this policy carefully.

SCOPE
Effective January 10, 2022, all LaGrange College employees, and workers are required to be either fully vaccinated against COVID-19 or submit a negative COVID-19 test result weekly. Persons subject to this policy include:

• Full-time employees (Faculty and Staff).
• Part-time, temporary, student workers, seasonal and hourly workers; and work study students

Remote workers are subject to this policy only in the event that they visit the office or come into physical contact with LaGrange College employees, workers or customers. In that event, no matter how short the duration (e.g., one day or even just a few minutes), they must submit proof of full vaccination or a negative COVID-19 test dated no more than seven days prior to their return to the workplace.
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All persons subject to this policy and hired after January 10 are required to be fully vaccinated by their first day of work or submit a negative test result dated no more than seven days prior to their first day of work, with subsequent weekly testing as described below.

PROCEDURES

Persons subject to this policy have two options:

Option 1: Provide Evidence of Full Vaccination

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Persons subject to this policy who choose to receive a COVID-19 vaccine will need to be fully vaccinated. For the purpose of this policy, persons are considered fully vaccinated:

• Two weeks (14 days) after their second dose in a 2-dose series, such as the Pfizer-BioNTech or Moderna vaccines, or
• Two weeks (14 days) after a single-dose vaccine, such as Johnson & Johnson’s Janssen vaccine.

If you do not meet these requirements, regardless of your age, you are NOT fully vaccinated. Booster shots are not required to be fully vaccinated.

COVID-19 vaccines are free and widely available at more than 80,000 locations across the country, including more than 40,000 retail pharmacies. Search vaccines.gov, text your ZIP code to 438829, or call 1-800-232-0233 to find locations near you.

All persons subject to this policy will be able to use up to four hours of sick leave to receive vaccinations during work hours, as well as the use of sick leave (as needed) to recover from any vaccine-related side effects. Employees should consult with their managers to schedule necessary time off. If no sick leave nor vacation time is available, accommodations will be made on a case-by-case basis.

Documentation of Vaccination Status

Official documentation of vaccination status must be emailed to the Human Resources Department prior to January 10th. Copies will be placed in a secure area, separate from employee personnel files. Acceptable proof of vaccination status is:  

1. The record of immunization from a healthcare provider or pharmacy;
2. A copy of the COVID-19 Vaccination Record Card;
3. A copy of medical records documenting the vaccination;
4. A copy of immunization records from a public health, state, or tribal immunization information system; or
5. A copy of any other official documentation that contains the type of vaccine administered, date(s) of administration, and the name of the healthcare professional(s) or clinic site(s) administering the vaccine(s).

Proof of vaccination generally should include the employee’s name, the type of vaccine administered, the date(s) of administration, and the name of the healthcare professional(s) or clinic site(s) that administered the vaccine. In some cases, state immunization records may not include one or more of these data fields, such as clinic site; in those circumstances LaGrange College will still accept the state immunization record as acceptable proof of vaccination.

If an employee is unable to produce one of these acceptable forms of proof of vaccination, despite attempts to do so (e.g., by trying to contact the vaccine administrator or state health department), the employee can provide a signed and dated statement attesting to their vaccination status; attesting that they have lost and are otherwise unable to produce one of the other forms of acceptable proof; and including the following language:

“I declare (or certify, verify, or state) that this statement about my vaccination status is true and accurate.  I understand that knowingly providing false information regarding my vaccination status on this form may subject me to criminal penalties.” 

An employee who attests to their vaccination status in this way should, to the best of their recollection, include in their attestation the type of vaccine administered, the date(s) of administration, and the name of the healthcare professional(s) or clinic site(s) administering the vaccine.

Do not include any medical or genetic information with your proof of vaccination.

Note that a recent antibody test cannot be used to prove vaccination status.

‍All persons subject to this policy must certify that the documentation they are submitting is true and correct. Any persons found to have provided false documentation will be subject to termination of employment.
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Option 2: Submit to Weekly Testing

Persons subject to this policy who choose not to be vaccinated against COVID-19 must electronically submit a negative COVID-19 test result weekly each Monday morning to the Director of Human Resources at hr@lagrange.edu before reporting to work. Tests can be taken no earlier than 72 hours (Friday) before the test submission due date (Monday).
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Persons who choose not to be vaccinated are responsible for obtaining a weekly COVID-19 test at the employee’s cost. Acceptable tests include rapid antigen or PCR tests. An at-home rapid antigen or PCR tests may not be both self-administered and self-read by the employee unless it is observed by LaGrange College or an authorized telehealth proctor.
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Any persons found to have provided false documentation will be subject to termination of employment.
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OSHA Face Covering Requirement for Unvaccinated Individuals

LaGrange College has the prerogative to apply a more restrictive face covering requirement as long as the college follows CDC and DPH guidelines. Regardless of the college’s overall face covering requirements, at a minimum, the college must enforce the following protocol to be compliant with OSHA.

Effective January 10, 2021, any employee who is not fully vaccinated must wear a face covering when indoors or when occupying a vehicle with another person for work purposes. An employee who is alone in a room with floor to ceiling windows and a closed door may remove their face covering but must put it back on if they exit the room or another individual enters the room. An employee may also remove their face covering for a limited period while eating or drinking at the workplace, or for identification purposes in compliance with safety and security requirements.

Face coverings must consist of at least two layers of material that is either tightly woven or non-woven, and the face covering must not have visible holes or openings. Face coverings must completely cover the wearer’s mouth and nose, must fit snugly against the sides of the face without gaps, and must be replaced when wet, soiled, or damaged.

Procedures in the Event of a Positive COVID-19 Test

Any person covered by this policy who tests positive for COVID-19, regardless of their vaccination status, must notify their supervisor and the Director of Human Resources at LaGrange College as soon as safely possible. That notification should be done via phone call to supervisor, via email to the Director of Human Resources.

LaGrange College is required to temporarily remove from the workplace any person who tests positive for COVID-19. Those employees may work remotely per the current COVID-19 emergency remote work policy and agreement form submitted within two days of start. A person who tested positive for COVID-19 may return to the workplace:

• if they receive a negative result on a COVID-19 PCR for accurate test results; or
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• (1) after isolating for 10 days from the date of their positive test (if they never experienced symptoms), or at least 10 days have passed since the first appearance of any symptoms; AND (2) the person has gone at least 24 hours without a fever (without the use of fever-reducing medication); AND (3) the person’s other symptoms of COVID-19 are improving (excluding loss of taste and smell).

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POLICY ADMINISTRATION AND QUESTIONS

The COVID-19 Task Force and Human Resources is responsible for administering and enforcing this policy. If you have any questions about this policy or about health and safety issues that are not addressed in this policy, please contact the Director of Human Resources.
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POLICY MODIFICATION

Government and public health guidelines and restrictions and business and industry best practices regarding COVID-19 and COVID-19 vaccines are changing rapidly as new information becomes available, further research is conducted, and additional vaccines are fully approved and distributed. LaGrange College reserves the right to modify this policy at any time in its sole discretion to adapt to changing circumstances and business needs, consistent with its commitment to maintaining a safe and healthy workplace.
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ENFORCEMENT AND NON-RETALIATION

Failure to comply with or enforce this policy may result in discipline, up to and including termination of employment.

LaGrange College prohibits any form of discipline, reprisal, intimidation, or retaliation for reporting a violation of this policy or any other health and safety concern. Employees also have the right to report work-related injuries and illnesses, and LaGrange College will not discharge or discriminate or otherwise retaliate against employees for reporting work-related injuries or illnesses or good faith health and safety concerns.
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CONTINUED APPLICABILITY OF OTHER INFECTION CONTROL POLICIES

This COVID-19 Vaccination Policy is a key part of LaGrange College’s overall strategy and commitment to maintaining a safe and healthy workplace. This policy is designed for use together with, and not as a substitute for, other COVID-19 prevention measures, including LaGrange College's:

• Mask and Social Distancing Policy
• Temperature Check and Health Screening Protocols
• Cleaning and Sanitation Protocols
• Emergency Preparedness Plan
• Other COVID-19 Prevention Protocols

CONFIDENTIALITY AND PRIVACY

CONFIDENTIALITY AND PRIVACY
All medical information collected from individuals, including vaccination information, test results, and any other information obtained as a result of testing, will be treated in accordance with applicable laws and policies on confidentiality and privacy.

REASONABLE ACCOMMODATION

LaGrange College has a continued commitment to reasonable accommodation as stated in the Americans with Disabilities Act (ADA.)

QUESTIONS

Please direct any questions regarding this policy to Human Resources.